2025 – Edition 6 – July 3
Table of Contents
Note: The order of material varies in hotline emails, but is always presented the same on this landing page. Readers scrolling through content on or printing this page will find it organized consistent with the table of contents.
The President’s Desk
So We Don’t Have To
An old Dow Chemical advertisement promised ease. The cleaner’s “Scrubbing Bubbles” churned across bathroom tile and fixtures, disappearing dirt and grime. “We do the work,” the Claymation scrubbers promised from the now-gleaming surface, “so you don’t have to.”
ARSA’s team is similar; while it’s not quite right to say that ARSA works so its industry doesn’t have to as editorials and news reports highlight collective work that engaged and proactive members are doing for themselves so others can too. What is right to say about the association is that it does what shouldn’t have to be done.
In June, Executive Vice President Christian Klein spent a week in Germany participating in the yearly FAA-EASA International Safety Conference. In addition to utilizing German language skills from childhood years in Europe, Christian spoke on a panel, gave a “flash talk,” met with international leaders, and collaborated with colleagues.
During the trip, he unveiled months of ARSA effort – still ongoing – to put members ahead in making sense of and complying with new foreign repair station drug and alcohol testing requirements.
He also shared perspective on years of preparation for safety management system requirements imposed under the American/European bilateral relationship.
In short, ARSA shared vital work at a high level, policy focused event where every regulatory mind that matters attends.
While the association carried the industry’s water to Europe, members continued performing work, serving customers, and executing against business needs. By doing work so members don’t have to, the association expands influence, saves time, and makes good on the investment made in collective progress.
This edition of the hotline includes coverage of the conference as well as ARSA’s continual work for its global membership. The team does an awful lot so we don’t have to…really, it does the work so we can do even more.
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John Riggs 2025 ARSA president | Director of Airworthiness, Chromalloy |
Conference 2026
Turning the Corner
March 17-20, 2026
ARSA’s 2025 Annual Conference wrapped just more than 100 days ago and the team has turned the corner towards next year’s event. Registration for 2026 opens in 150 days (mark your calendar for the hotline’s Dec. 5 distribution).
Members turning the corner can budget for sponsorship, attendance, and travel. The event will again center around the Ritz-Carlton, Pentagon City in Arlington, Virginia with supporting activities around the nation’s capital.
Basic Schedule
Executive to Executive Briefings: Tuesday, March 17, 2026
Participation by industry executives with senior executive branch officials and key aerospace allies is limited to annual conference sponsors.
Legislative Day: Wednesday, March 18, 2026
Dedicated to educating both the aviation maintenance industry and elected officials. Learn (or brush up) on what ARSA does and what you can do to prepare for afternoon visits with targeted Capitol Hill legislators and staff.
Annual Repair Symposium: Thursday, March 19, 2026
The centerpiece of Conference week, ARSA convenes a full day of substantive panel discussions covering key regulatory compliance and business issues. After the keynote address, regulators from across the world join the “Opening Salvo” conversation, followed by lunch, and an afternoon of practical regulatory and business discussion.
Member Day: Friday, March 20, 2026
ARSA’s leadership briefs members on the state of the association as well as goals and priorities for the coming year. Participants then close out the event by participating in breakout and/or training sessions focused on key aerospace topics. The Conference ends by 12:00 p.m. EDT.
2025 in Review
Look back at last year to bask in the memories or see what you’ve been missing.
Executive to Executive Briefings: Tuesday, March 18, 2025
Participation by industry executives with senior executive branch officials is limited to annual conference sponsors at the Administratium, Platinum, Gold, or Silver levels. In past years, meeting participants included representatives from the U.S. Departments of Commerce, Defense, Labor, State, and Transportation as well as the fellow trade associations and industry interest groups. Schedule Subject to Change9:00 a.m. | Introductory Briefing
10:00 a.m. | U.S. Department of State
Heidi Gomez, Deputy Assistant Secretary for Transportation Affairs, Bureau of Economic and Business Affairs
With an eye to the volatile geopolitical environment, Deputy Assistant Secretary Gomez will discuss issues impacting bilateral relationships, the bilateral negotiation process, and opportunities to influence the development of bilaterals.
11:00 a.m. | Break
11:15 a.m. | Regulatory Reform: Opportunities and Risks
Andrew Langer, President, Institute for Liberty and Director, CPAC Foundation Center for Regulatory Freedom
As an advocate, policy communicator, academic, and radio talk show host, Langer has dedicated his career to building public awareness about the shortcomings of the federal bureaucracy and, more importantly, how to improve government oversight. He will discuss the historic opportunity presented by the Trump administration to improve government operations and how the business community can help steer reform in the right direction.
12:15 p.m. | Talking Trade and Tariffs
Dak Hardwick, Vice President, International Affairs, Aerospace Industries Association, Invited
The aviation maintenance industry is facing supply chain disruptions and the potential impact of tariffs on parts and raw materials. Hardwick will discuss risks in the current environment and opportunities for the aerospace industry to steer the public discussion about aviation manufacturing, trade, and tariffs in the right direction.
1:00 p.m. | Lunch
2:00 p.m. | Importing Talent: Challenges and Opportunities
Laura Footre Reiff, Shareholder, GreenbergTraurig, Founder, Essential Worker Immigration Coalition, Invited
EWIC is a broad-based coalition of businesses and trade associations that support comprehensive immigration reform to address the technical talent shortage. Reiff will discuss opportunities to improve the U.S. immigration system and share strategies for importing talent.
3:00 p.m. | Break
3:15 p.m. | Economic Impacts
Livia Hayes, Director, Market Intelligence Team, Transportation and Services Practice, Oliver Wyman
Hayes will reveal the findings of the most recent Oliver Wyman MRO industry forecast and lead a roundtable discussion of factors and trends impacting demand for aerospace maintenance services.
4:00 p.m. | Wrap Up
Legislative Day: Wednesday, March 19, 2025
The day dedicated to educating both the aviation maintenance industry and elected officials. Learn (or brush up) on what ARSA does and what you can do so you're ready for afternoon visits with targeted Capitol Hill legislators and staff.7:30 a.m. | Registration and Breakfast
8:00 a.m. | Welcome and Introductions
Christian Klein, Executive Vice President, ARSA
Alex De Gunten, Vice President of Government & Industry Affairs, HEICO and ARSA 2025 Government Affairs Chairman
8:15 a.m. | It's All About Your Industry and Your Company
Christian Klein, Executive Vice President, ARSA
9:00 a.m. | The View from the Hill
Karen Huggard, Vice President of Government Affairs, National Air Transportation Association
Jarrod Thompson, Vice President for Legislative and Regulatory Policy, Airlines for America
Moderator: Christian Klein, Executive Vice President, ARSA
9:45 a.m. | Break
10:00 a.m. | National Defense Authorization Act: Accomplishments and Opportunities
Josh Krotec, Senior Vice President, First Aviation and ARSA Immediate Past President
Alex de Gunten, Senior Vice President for Government & Industry Affairs, HEICO and 2024 ARSA Government Affairs Chairman
Mandy Smithberger, Senior Adviser, National Security, Sen. Elizabeth Warren (D-Mass.)
Moderator: Christian Klein, Executive Vice President, ARSA
10:30 a.m. | Strengthening Our Roots
Christian Klein, Executive Vice President, ARSA
11:00 a.m. | Global Fleet & MRO Market Report Release presented by Oliver Wyman
Livia Hayes, Director, Oliver Wyman Vector
11:30 a.m. | Wrap Up
12:00 p.m. | Lunch & Adjourn
1:00 p.m. | Congressional Meetings Begin
TBD | Presentation of 2025 Legislative Leadership Award
TBD | House Aviation Subcommittee Staff Briefing (on Capitol Hill)
4:00 p.m. | Symposium Registration Open (for non-Legislative Day attendees)
5:30 p.m. | Ice-Breaker Reception
7:00 p.m. | Special Invitation Dinner
Annual Repair Symposium: Thursday, March 20, 2025
The centerpiece of Conference week, ARSA convenes a full day of substantive panel discussions covering key regulatory compliance and business issues. After the keynote address, regulators from across the world join the full-morning "Opening Salvo" conversation, followed by lunch and an afternoon of practical regulatory and business discussion.7:30 a.m. | Registration and Breakfast
8:00 a.m. | Welcome and Introductory Remarks – What ARSA Has Done Lately
Sarah MacLeod, Executive Director, ARSA
Christian Klein, Executive Vice President, ARSA
8:30 a.m. | Session 1: Fireside Chat with AIR
Caitlin Locke, Executive Director, Aircraft Certification Service
Moderator: Sarah MacLeod, Executive Director, ARSA
9:00 a.m. | Break
9:30 a.m. | Session 2: Opening Salvo – Conversations with the Regulators
Lawrence Josuá Fernandes Costa, Continuing Airworthiness Certification Manager, Department of Flight Standards, ANAC Brazil, ONLINE
Ludovic Aron, Washington Representative, EASA
Karl Specht, Principal Coordinator Organisation Approvals, EASA, ONLINE
Robert Ruiz, Acting Executive Director, Flight Standards Service, FAA, Invited
Dan Elgas, Director, Policy and Standards Division (AIR-600), Aircraft Certification Service, FAA, Invited
Neil Williams, Head of Airworthiness, Policy & Rulemaking, United Kingdom Civil Aviation Authority
10:45 | Break (Approximate; Session 2 to continue)
12:30 p.m. | Lunch and Special Presentation
2:00 p.m. | Best Approaches to Rulemaking
Tony Fazio, President, Fazio Group International
Lirio Liu, Executive Director, Willow Aviation Advisors
Sarah MacLeod, Executive Director, ARSA
Moderator: Brett Levanto, Vice President of Operations, ARSA
3:00 p.m. | ARSA Quiz Show
3:30 p.m. | Break
4:00 p.m. | More than an Apprentice
Jennifer Evans, CEO, Compressed Gas Systems
Quincy Gellerman, Student
Moderator: Brett Levanto, Vice President of Operations, ARSA
5:00 p.m. | Aerospace Happy Hour
Member Day: Friday, March 21, 2025
ARSA's leadership briefs members on the state of the association as well as goals and priorities for the coming year. Participants then close out the event by participating in breakout and/or training sessions focused on key aerospace topics. The Conference ends by 12:00 p.m. EDT.8:00 a.m. | Annual Membership Meeting and Breakfast
9:30 a.m. | Break
10:00 a.m. | Training Sessions & Breakout Discussions
HazMat Determinations – An ARSA training session on determining whether your company is a Hazardous Materials employer under the rules in 49 CFR and the regulatory requirements that all maintenance providers should heed. (One Hour)
Complying with Foreign D&A Requirements – An ARSA training session helping repair stations get ahead of the December 2027 compliance date for the new rule expanding drug & alcohol testing requirements to facilities located outside the United States. All maintenance personnel, regardless of location, should understand the industry-wide impact of the new rule. (One Hour)
Repairman to Specialist – An open discussion with industry and education leaders on developing career (and certification) pathways through 14 CFR part 65 subpart E.
12:00 p.m. Conference Ends
In-Person
All substantive and social activities were hosted at the Ritz-Carlton, Pentagon City in Arlington, Virginia. Legislative Day participants will head to Capitol Hill for meetings with congressional offices as appropriate.
Livestream
The majority of Conference events will be available to livestream viewers via a Vimeo web-player embedded into a page on ARSA.org. All in-person registrants will be able to name a "Conference Ambassador" as a contact to access the livestream and bring the event back to their home facilities. Paying registrants for livestream access may share with multiple company contacts. Livestream participation will include a mechanism for submitting questions to onsite personnel.
Pricing
| Executive to Executive Briefings | ||||
| Open to Administratium, Platinum, Gold, and Silver-level sponsors. | ||||
| Legislative Day – Wednesday, March 19 | ||||
| Members | Non-Members | |||
| First | Additional | First | Additional | |
| In-person | $400 | $360 | $600 | $540 |
| Livestream Free with in-person registration. | $400 | $600 | ||
| Symposium – Thursday, March 20 | ||||
| In-person | $900 | $810 | $1,250 | $1,125 |
| Livestream Free with in-person registration. | $900 | $1,250 | ||
| Legislative Day & Symposium Bundle | ||||
| In-person | $1,100 | $990 | $1,500 | $1,350 |
| Livestream Free with in-person registration. | $1,100 | $1,500 | ||
| The Super Bundle (Silver Sponsorship, E2E, Legislative Day, & Symposium) | ||||
| In-person | $4,200 | $4,500 | ||
| Livestream Free with in-person registration. | ||||
| Member Meeting & Training/Breakouts – Friday, March 21 | ||||
| In-person | Free with Symposium registration. | |||
| Livestream | ||||
(2) Registration fees may be waived for government personnel, members of the media, speakers, and other support personnel or special guests upon approval by the ARSA event team.
Administratium – $20,000
What is Administratium? An element aerospace professionals see every day (click here to learn more). Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, additional advertising placement via ARSA’s communications, complimentary registrations for three (3) participants in the Executive to Executive Briefings as well as three (3) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Administratium Level, sponsors may select one of the following* to specifically support (please note the list in this document does not reflect current availability):- Annual Repair Symposium – Ice Breaker Reception
- Annual Repair Symposium – Thursday Happy Hour
- General Sponsorship
Platinum – $10,000
Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, complimentary registrations for three (3) participants in the Executive to Executive Briefings as well as three (3) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Platinum Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2025):- Online Conference Experience
- Executive to Executive Briefings
- Legislative Day – All Day
- Congressional Directories/Resources
- General Sponsorship
2024 Platinum Sponsors
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Gold – $7,500
Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, complimentary registrations for two (2) participants in the Executive to Executive Briefings as well as two (2) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Gold Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2025):- Legislative Priorities Brochures/Resources
- Digital Companion/Electronic Materials
- Legislative Day – Continental Breakfast
- Legislative Day – Congressional Briefing and Luncheon
- Annual Repair Symposium – Continental Breakfast
- Annual Repair Symposium – Luncheon with Special Guest
- Nametag Lanyards
- Hotel Room Keys
- General Sponsorship
2024 Gold Sponsors
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Silver – $3,500
Notation in all publicity, marketing, and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, complimentary registrations for one (1) participant in the Executive-to-Executive Briefings as well as one (1) in Legislative Day. At the Silver Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2024):- Annual Repair Symposium – Coffee Break (5)
- General Sponsorship
2024 Silver Sponsors
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Supporter – $2,500
Notation in all publicity, marketing, and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, specific email alerts to association contacts), and recognition in event materials and from the podium.Contributor – $500 to $2,499 (or equivalent support)
Notation in some publicity, marketing, and periodicals (e.g., the hotline, Dispatch), and recognition in event materials and from the podium.2024 Contributors
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ARSA's block of rooms for Conference participants at the Ritz-Carlton, Pentagon City in Arlington, Virginia is now closed. The hotel hosts most of the activities related to the ARSA Conference and is convenient to the Metro as well as Washington Reagan National Airport (DCA). To try and book a room independently, go to the hotel's website or call 703.415.5000.
Those seeking other options may consider these hotels (there are no ARSA-related specials or promotions at these locations):
Embassy Suites by Hilton Crystal City National Airport, 1393 S Eads Street Arlington, Virginia, 22202
Residence Inn Arlington Capital View, 2850 South Potomac Avenue Arlington, Virginia, 22202
DoubleTree by Hilton Hotel Washington DC – Crystal City, 300 Army Navy Drive Arlington, Virginia, 22202
Crowne Plaza Washington National Airport, 1480 Crystal Drive Arlington, Virginia, 22202
Hampton Inn & Suites Reagan National Airport, 2000 Richmond Highway Arlington, Virginia, 22202
Radisson Hotel Reagan National Airport, 2020 Richmond Highway Arlington, VA 22202
Holiday Inn National Airport/Crystal City, 2650 Richmond Highway Arlington, Virginia, 22202
The Leo Weston Award for Excellence in Government Service
First bestowed on Leo Weston himself in 2005, the Weston award honors an instrumental figure in ARSA's birth by recognizing individuals who embody his commitment to the industry's safety and success. The symposium provides a venue for association members and invited guests from around the world to network and discuss issues that matter to the aviation maintenance industry. It is the perfect time to respect the history of the repair station community and honor the good works of those who support it.
Click here to learn more about Leo, the award bearing his name, and those who have received it.The Legislative Leadership Award
The association regularly recognizes members of Congress who have provided outstanding support to the aviation maintenance community by supporting policies beneficial to the industry. Honorees have each been key in moving forward specific legislation advancing priorities championed by ARSA on behalf of its members.
Click here to see past updates regarding Legislative Leadership Award recipients.The "Golden Shovel" Award
From time to time, ARSA recognizes individuals – usually at the time of their retirement – who have spent their careers in steadfast devotion to good business, good safety, and good oversight. In the colorful illustration of Executive Director Sarah MacLeod, these professionals have spent their lives shoveling against the tide of government bureaucracy; their achievement in never giving up is acknowledged through the "Golden Shovel Award."
Click here to learn more about the "Shovel" and see who has received it.Event Photos
ARSA has created a Google Album including photos taken during the 2025 Annual Conference, which allows participants to share their own photos (Sharing event photos constitutes consenting to their use/distribution in association with Conference-related publicity for this or future events, at ARSA’s discretion). To see the album, click here.Recordings
Complete "raw" recordings are accessible by attendees via the Digital Companion. The ARSA team will utilize recorded content throughout the year in support of its communications. If you’re looking for a specific segment or need assistance with a recording, contact ARSA.The following excerpts were provided to ARSA members via the hotline newsletter. They are included here as examples of the event's content.
Legislative Day Briefing – Market Report ReleaseLeaders from Oliver Wyman Vector presented report findings to Legislative Day participants on March 19, illustrating the current and projected states of the North American and global aircraft fleets and related impacts on maintenance demand. This data illustrates the current state of the aerospace marketplace and provides insight for future business considerations. The briefing is provided in its entirety for the benefit of members.
Symposium Briefing – What Has ARSA Done LatelyThe brief session includes updates about key work performed by the association in the last year as well as instruction for maximizing membership value while helping move the enterprise forward.
Symposium Q&A – Foreign D&A TestingThe three-hour “Opening Salvo” is unlike anything else in the aerospace event cycle: Four regulatory authorities from three continents providing updates and engaging in substantive discussion with attendees. In this clip from the 2025 panel, a participant question produces more than ten minutes of discussion from the panelists.
Weston Award Recognizes Crowley’s Commitment to LearningOn March 20, ARSA recognized Jerry Crowley with its Leo Weston Award for Excellence in Government Service. Crowley is a long time FAA aviation safety inspector who was a professional protégé and friend to the award’s namesake.
Planning Ahead
Help ARSA’s team put together the 2026 Annual Conference by answering a few questions at www.surveymonkey.com/r/ARSAConferencePlan.
ARSA Works
Review FAA’s Methods, Techniques, and Practices
The FAA has engaged industry to help review AC 43.13-1B Acceptable Methods, Techniques, and Practices—Aircraft Inspection and Repair that is applicable to aircraft inspection and repair. The AC primarily supports independent mechanics, technicians, and repair stations maintaining general aviation aircraft.
The agency’s review focuses on:
(1) Clarifying and revising the content.
(2) Eliminating redundancy.
(3) Updating for new technologies.
On July 15-16, the FAA will convene an in-person meeting of industry representatives. The Aircraft Electronics Association’s Ric Peri will represent ARSA members.
To support AEA and ARSA’s effort, please complete the following survey.
If you have questions about the AC or the effort to update it, contact Ric Peri.
If the embedded survey does not appear/load, open the survey independently by visiting: https://www.surveymonkey.com/r/ac-43_13_1-review.
Note: The question is displayed in its own, embedded window. If the “Submit” button is not visible on the screen, you must scroll within the survey window to submit your response.
Drafting Regulatory Purpose into Order 8130.21
On June 17, ARSA and the Aircraft Electronics Association (AEA) jointly submitted a rewrite of the FAA’s Draft Order 8130.21J, “Completion of FAA Form 8130-3 under 14 CFR part 21.” The submission overhauled the FAA’s draft to make clear the different sections and paragraphs of the production rule under which the form is used to issue an airworthiness approval or an authorized release.
“The only method of determining the difference between an airworthiness approval and authorized release is by the type of certificate or authorization provided in the signature block [of the 8130-3],” the associations said in the cover letter supporting their submission. “It is the regulations approving or authorizing issuance of the form that dictate the type of certification or authorization allowed in the signature block.”
During ARSA’s Annual Conference in March, FAA Director of Aircraft Certification Caitlin Locke announced the draft’s posting: ““[Order 8130.21] used to be…75 pages and now it’s 18. [The agency wants to highlight] examples of where we’re able to do that, where we’re able to meet the intent of what the guidance or the policy is for, to give the explanatory information that’s needed, but not add so much that then you need more guidance to interpret what you said because what you said before wasn’t clear, so you’re saying it again and now it’s not clear and you have six more forms and you don’t know why.”
The jointly rewritten draft submitted by ARSA and AEA maintained this brevity (16 pages) while refocusing its instructions on the purposes and regulatory authorities associated with the form. The submission’s section outlining the use of the 8130-3 under part 21 provides two avenues for issuance:
Paragraph 8.a. When issued by the FAA or its designees, including ODA-UMs, the FAA Form 8130-3 is an airworthiness approval…
Paragraph 8.b. When issued as an authorized release document (ARD) under 14 CFR § 21.137(o), the PAH will do so in accordance with the quality system procedures submitted and approved under 14 CFR § 21.138…
The association’s draft provides completion instructions with regulatory citations and cross-references to support the guidance document. The updated block-by-block template organizes examples based on the use of the form – authorized release or airworthiness approval (including domestic identification, domestic prototype, and export).
The rewrite was delivered after an industry-supported request for extension to the original comment period and circulated to the organizations that sought the extra time. ARSA, AEA, and their allies will work directly with the FAA regarding the substance of the submission and are encouraging the government to seek public review.
ARSA encourages its members to click here to download and review the rewritten draft, then stay tuned for opportunities to engage the FAA on its implementation.
ARSA Leads D&A Action at EASA-FAA Conference
ARSA Executive Vice President Christian Klein joined global aviation regulators and industry leaders in Cologne the week of June 9 for the annual EASA-FAA Safety Conference. Klein attended to present on key industry issues and report on bilateral updates affecting U.S. and European maintenance organizations.
FAA Aircraft Certification Service Policy and Standards Division Director Dan Elgas announced revision 7.1 of the FAA-EASA Technical Implementation Procedures for Airworthiness and Environmental Certification (TIP) was signed June 10. ARSA is hopeful the new TIP will resolve long-standing paperwork-related inconsistencies between the FAA and EASA systems. Jackie Black, manager of the FAA Flight Standards Service’s Aircraft Maintenance Division, reported that revision 10 of the FAA-EASA Maintenance Annex Guidance (MAG) will likely be signed within weeks.
ARSA has spent the last decade untangling problematic paperwork mandates stemming from MAG Change 5, which became effective in September 2015. EASA has since demanded an FAA Form 8130-3 accompany all new parts consumed during maintenance on a higher level assembly under the bilateral. The requirement is impracticable because FAA production approval holders are not required to provide an the form for new parts. While authorities have indicated the new TIP will address the paperwork requirement, the text is yet to be made public.
Klein gave a flash talk about the FAA’s new drug and alcohol (D&A) requirements for certificated repair stations outside the United States. He reviewed the new rule, discussed compliance challenges, and previewed the in-development ARSA toolkit for member companies and their governments to apply for waivers and exemptions. Klein urged foreign stakeholders to start planning now to handle the new rule’s complexities well before the December 2027 compliance date.
Klein also participated in a June 11 panel moderated by Black on repair station safety management system (SMS) implementation. Black reported that despite the Dec. 31, 2025 compliance deadline, only around 40 U.S. repair stations with EASA approval have taken the necessary steps to fully comply with the bilateral SMS requirements.
ARSA members are encouraged to build their SMS programs utilizing resources available through the association’s partnership with the Aircraft Electronics Association (AEA). Click here for more information and to apply for access.
Were you (or a colleague) at the FAA/EASA Conference? Would you like more information about the event and ARSA’s representation of the industry there? Contact the association with questions or comments.
To see coverage a previous International Aviation Safety Conferences, review the content at arsa.org/faa-easa-conference.
Correct STC Oversight Problems
STC holders should take advantage of summertime opportunities to highlight FAA oversight issues to government auditors.
Congress’ May 2024 reauthorization of the FAA, required the Department of Transportation’s Office of Inspector General (OIG) to audit the FAA’s Flight Standards and Aircraft Certification Services (see P.L. 118-63, Sec. 821). Last November, the first of three audits mandated by the law was initiated to address consistency of FAA oversight of supplemental type certificates.
The OIG has two objectives for its initial audit of the FAA. It intends to determine whether:
(1) The FAA has sufficient controls in place to provide reasonable assurance that inspectors are consistent in determining what aircraft alterations require an STC.
(2) FAA inspectors process STC applications consistently across FAA offices and geographic regions.
ARSA members holding STCs must provide the OIG input to support these determinations. The association has two opportunities for doing so this summer:
(1) Meet directly with the OIG audit team. Interested members should email the audit team lead directly to schedule an in-person meeting or inquire about online connection options.
(2) Answer ARSA’s ongoing “quick question” by visiting https://www.surveymonkey.com/r/STC_audit.
Final Documents/Your Two Cents
This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members.
Regulatory Update
FAA/EASA MAG Change 10 Released
On June 20, ARSA learned of the publication of change 10 to the Maintenance Annex Guidance between the FAA and EASA, which is issued under bilateral agreement between the United States and European Union. As discussed and expected for more than a year, the change includes a requirement for U.S.-based repair stations holding EASA approval to implement a safety management system (SMS).
The compliance date for the new MAG is Oct. 10. The document is silent on the long-understood December 2025 deadline for existing approval holders to develop, implement, and maintain an SMS; ARSA is working with the FAA on an updated notice regarding renewal expectations. New applicants – including those who have previously surrendered or failed to renew their approval – have been required to meet EASA’s SMS standard since the February 2025 update to Annex 2.
As reported in February, Annex 2 of the bilateral agreement was updated to include a special condition requiring SMS. MAG Change 10 provides specificity related to that requirement aligned with previous agency communications regarding compliance with the FAA’s voluntary program. Applicants and approval holders must submit a “declaration of compliance” to their FAA office attesting to their implementation of SMS.
[MAG Section B: Appendix 1, Paragraph 20.0] Safety Management System (SMS). Repair stations must establish, implement, and maintain an SMS to hold EASA approval. Implementation of the FAA SMS voluntary program, which meets 14 CFR part 5 requirements, is the minimum expectation that repair stations must maintain for compliance with an SMS that is acceptable to EASA. An SMS must be integrated into the repair station’s processes and procedures that support the EASA special conditions and daily operations of the repair station. The SMS must, at a minimum, include the requirements outlined in the SMSVP. The SMS declaration must be submitted with the EASA application. The SMS must be appropriate to the size, scope, and complexity of the repair station’s operations. The following must be integrated into the SMS, Subparts A-F of the SMSVP:
a. Applicability-subpart A
b. Safety Policy-subpart B
c. Safety Risk Management-subpart C
d. Safety Assurance-subpart D
e. Safety Promotion-subpart E
f. Maintained in accordance with the recordkeeping requirements-subpart F
g. Ensure compliance with the EASA special conditions and 14 CFR parts 43 and 145
ARSA members that have not already done so – more than 90 have already sought more information – should review the SMS tools available through the association’s partnership with the Aircraft Electronics Association.
To download the complete MAG, click here.
Record of Revisions – MAG Change 10
Global Change:
EASA Form 3 has been revised to EASA Form 3-145
Section A:
Paragraph 5.0, Special Conditions, subparagraph 5.1.1.1(b), added new SMS special condition
Paragraph 5.1.1.1(c)(12), added new SMS special condition EASA supplement requirement
Appendix 2, Form 8, added paragraph 20 SMS
Appendix 3, Form 10, added language to numbers 17, 20, and 26. Renumbered form
Appendix 10, added (c) definition of declaration of compliance
Appendix 10, added (m) definition of SMS
Appendix 10, added (n) definition of SMSVP
Section B:
Paragraph 1.0, subparagraph 1.2.1a–d, added Note and declaration of compliance requirements
Paragraph 1.2.2, Evidence of Need revised sentence to apply for/hold
Paragraph 1.2.3, added declaration of compliance
Paragraph 1.3.1, revised paragraph by adding declaration of compliance and copy of the repair station Vitals showing SMSVP
Paragraph 1.3.3, revised paragraph adding routine surveillance and including SMS performance
Paragraph 1.3.8(b) and (f), added Vitals and declaration of compliance
Paragraph 1.4.1, revised paragraph to include Vitals and declaration of compliance
Paragraph 2.0, subparagraph 2.1.2(b), added requirement to submit declaration of compliance
Paragraph 2.1.3, added declaration of compliance and Note
Paragraph 2.2.1, added declaration of compliance
Paragraph 2.2.2(c) and (f), added SMSVP and declaration of compliance
Paragraph 2.2.4, added withdrawal language
Paragraph 2.4.1, revised paragraph adding declaration of compliance and Vitals
Paragraph 2.4.4, SMSVP failure to comply non-recommendation
Appendix 1, paragraph 10.1, revised Note for new modification and replacement parts, TIP paragraph 7.10 provides detailed acceptance criteria
Appendix 1, paragraph 10.14, removed following subparagraphs and revised paragraph language
Appendix 1, paragraph 14.5.1.2(b), added Note
Appendix 1, paragraph 14.5.2.4, changed AMO to repair station
Appendix 1, added paragraph 20, SMS
Appendix 2, added block 20
Appendix 3, updated EASA email address in Note 4 and 5
Appendix 4, revised to include surveillance term, added block 6, added additional non-recommendation block
Section C:
Paragraph 2.2.8, added capability list for renewal
Paragraph 3.1.3.1, added capability list for change/amendment
Appendix 1, removed MOE expiration date
Appendix 1, added Note to Revision No. paragraph
Appendix 1, paragraph 2.0, added reference to paragraph 4
Appendix 1, paragraph 2.0, revised paragraph by adding exception of paragraph C
Appendix 1, paragraph 4.2.2, revised from acceptance to approval
Appendix 1, paragraph 7.1(f), Note, aligned language to part 43 return to service
Appendix 1, paragraph 7.6.2, revised paragraph to reflect new procedure and align with Section B; removed paragraphs 7.6.3–7.6.7
Appendix 1, paragraph 9.3.1, revised to former revision language to specific maintenance functions
MAG Compliance Matrices Updated
Following the publication of change 10 to the FAA/EASA Maintenance Annex Guidance, ARSA updated its cross-reference matrices for tracking bilateral compliance. The matrices provide a method to compare quality system/manual elements against the (1) special conditions and (2) supplement guidance included in the updated MAG.
Two versions of each updated matrix is available:
(1) A “RedLine” version tracking updates between MAG change 9 and 10. Existing users can follow the tracked edits to determine where attention is needed in their current systems.
(2) A “Clean” version showing just the language of MAG change 10. New users can incorporate the matrices into their repair station documents.
For immediate access – member status is validated after the request is made – click here to go to the publications page.
Legal Brief
Editor’s note: This material is provided as a service to association members for educational and informational purposes only. It does not constitute legal or professional advice and is not privileged or confidential.
D&A Complexity
By Christian Klein, Executive Vice President
Regulators are waking up to the significant compliance challenges associated with the FAA’s new foreign repair station drug and alcohol (D&A) rule. The congressionally mandated rule, finalized in December, requires FAA-certificated repair stations outside the United States whose employees perform safety sensitive functions on part 121 air carrier aircraft to have a 14 CFR part 120-compliant D&A program in place by Dec. 20, 2027.
The rule provides some compliance flexibility for proactive organizations. Under 14 CFR sec. 120.10, repair stations and their governments may seek a waiver from the requirements of 14 CFR part 120, subparts E and F based on their existing D&A programs and national requirements. Repair stations that do not obtain 14 CFR sec. 120.10 waivers must fully comply with 14 CFR part 120 and the U.S. Department of Transportation’s D&A rules at 49 CFR part 40. However, repair stations may also seek waivers and exemptions from individual requirements of those rules.
ARSA is preparing a toolkit, which will be released this fall, to help association members and their governments through the compliance maze. The toolkit identifies FAA and DOT rules likely to create the biggest compliance challenges and provides templates for waiver and exemption requests.
The FAA is also developing guidance for industry, which is expected to be released by the end of the year. As part of the guidance development process, ARSA submitted initial recommendations [LINK] to the FAA’s Drug Abatement Division on June 30. The association is urging the FAA to:
- Ensure sufficient agency personnel are trained and available to process the hundreds of requests the FAA will receive.
- Coordinate internally with other FAA business units (g., the Chief Counsel’s Office) so regulators and industry understand what role each will play (if any) in the waiver process.
- Create a website to allow stakeholders to track waiver applications and grants.
- Embrace the flexibility given to the agency by Congress and proactively waive impracticable 14 CFR part 120 and 49 CFR part 40 compliance requirements. For example, both rules require the use of labs certified by the U.S. Department of Health and Human Services (HHS) to process drug test specimens. However, there are no HHS certified labs outside the United States and Canada.
- Provide guidance to other departments and agencies that will be involved in implementation of the new rule.
- Limit applicability of the rule to airframe repair stations given that the law specifically references safety sensitive work on part 121 air carrier aircraft (e., not components and engines).
- Allow organizations with multiple repair stations (either multiple certificates or multiple facilities under a single certificate) to obtain a single waiver under secs. 120.9 or 10 applicable to all facilities.
- Confirm that parts pooling arrangements, in which no repair station is a maintenance contractor to an air carrier at any tier, are not impacted by the D&A rule.
ARSA welcomes input from members subject to the new rule regarding compliance challenges and opportunities to streamline compliance and implementation.
ARSA on the Hill
Grantham Gets Cycle’s First ARSA PAC Contribution
Air Force and aviation industry veteran Travis Grantham, a candidate for Arizona’s fifth congressional district, has received the first ARSA Political Action Committee (PAC) contribution of the 2026 election cycle. Grantham is running as a Republican to replace Rep. Andy Biggs (R), who is retiring from Congress to run for Arizona governor.
A third-generation Arizonan, Grantham enlisted in the United States Air Force/Arizona National Guard’s (ANG) 161st Air Refueling Wing while in college. He trained and served as an aircraft maintenance technician on the KC-135E Stratotanker, achieving the rank of staff sergeant.
Following his graduation from Arizona State University, Grantham was selected for pilot training, commissioned as a second lieutenant, and earned his wings in August 2003. He currently holds the rank of lieutenant colonel and serves as an aircraft commander, evaluator, and instructor pilot in the ANG with more than 3,000 hours in the KC135. He is also the 161st Air Refueling Wing’s deputy operations group commander.
Grantham joined ARSA member International Air Response (IAR) as a vice president in 2003 and purchased the company with his brother Bill (the current president) in 2009. Grantham served as IAR’s chief operations officer for several years before selling his interest.
In addition to his aviation experience, Grantham served in the Arizona State Legislature, including four years as speaker pro tempore.
“It’s not often that we see candidates with Travis’ background run for Congress,” ARSA Executive Vice President Christian Klein said. “We think his leadership experience in the military, politics, and aviation will make him a highly effective representative for a state with a big aerospace sector.”
ARSA PAC’s $1000 contribution to Grantham’s campaign was delivered on June 27. ARSA PAC is supported entirely by personal contributions from senior employees and owners of ARSA member companies. The resources are used to help congressional candidates who share ARSA’s commitment to reasonable and efficient regulatory oversight, the free market, and entrepreneurship.
To learn more about Grantham, click here. To learn more about ARSA PAC, click here.
Bedford Nomination Advances
The Senate Commerce Committee narrowly approved Republic Airways CEO Brian Bedford’s nomination to serve as the next FAA administrator. While Bedford’s industry experience has earned him the support of leading aviation groups, and Republican lawmakers, every Democratic committee member voted against advancing his nomination.
Their primary concern is that Bedford advocated for shortening the “1,500-hour rule”, which requires pilots to have at least 1,500 hours of training before operating a commercial aircraft. Industry groups have argued that the 1,500-hour rule is inflexible and makes it harder to recruit commercial pilots. Others, including Captain Sulley Sullenberger, believe it is essential to ensure pilots have experience flying in a variety of conditions before stepping onto the flight deck. Bedford’s nomination is also opposed by the families of victims of the 2009 Colgan Air flight 3407 crash, which wield significant political influence with New York’s congressional delegation.
The FAA has been operating under the leadership of Acting Administrator Chris Rocheleau since former Administrator Michael Whitaker’s resignation on Jan. 20. Despite the partisan committee vote, Bedford’s nomination is still expected to be approved by the Republican-controlled Senate, although a date for the vote not been announced.
Training & Career Development
Make ARSA Training Work
ARSA’s online training program represents its most-valuable benefit to the aviation industry: knowledge gained through training and experience. The association’s team has turned its decades of work on behalf of aviation maintenance into more than 80 hours of on-demand content.
While sessions are available for registration at any time – ARSA member discounts available – companies can also incorporate the association’s training into their regular programs:
(1) Subscription. Make up-front, bulk purchases of training hours. The details of each subscription can be customized, including focus on specific subject areas (e.g., human factors) or options for specially-priced session access after the initial hours have been used.
(2) “Championing” a session. Guarantee a certain number of attendees for training in a particular topic that will also be made available for general registration. Variations include open registration for a live session (i.e., company personnel participate at the same time as general registrants) or a company-specific live event for which a recorded version (not including any company-specific information) is made available for on-demand registration.
(3) Tailored training. Contract ARSA’s management firm Obadal, Filler, MacLeod & Klein, P.L.C. to produce or modify training specific to your organization. The team can then re-record it (or offer it as a separate live session) for ARSA’s training program. Tailored programs are priced differently from ARSA’s hourly rate and are administered by OFM&K, which allows for a client engagement and related attorney-client privilege for all discussion.
For more information about ARSA’s training program, review the menus below. If you have questions or would like to learn more about ways to integrate ARSA training into your own program, contact Vice President of Operations Brett Levanto (brett.levanto@arsa.org).
Government employees: Contact ARSA directly for auditing opportunities.
Registration: Registration and payment may be processed directly through the training platform/course catalog (free account creation required).
Technical questions and assistance: Click here for FAQ and technical support from training platform vendor.
Refunds: No refunds are granted for ARSA training sessions. When classes are canceled, registrants can choose from future courses of equal value. If a registrant is unable to attend a live session, their registration allows access to the on-demand, recorded version of the webinar.
IA Approval: A number of ARSA training sessions have been accepted for Inspection Authorization (IA) renewal credit. These sessions are denoted on their registration page with their FAA course acceptance number (in red).
Benefits: Registration for an ARSA-provided training session includes:
- Access to the live class session on the scheduled date (if applicable).
- Unlimited access to the on-demand, recorded version of the webinar to be made available after the live session is complete (or at time of purchase, for on-demand classes).
- A copy of the presentation and all reference material with links to relevant resources and citations.
- A certificate* upon completion of the session as well as any required test material.
OFM&K Training Portal: All of ARSA's training sessions are provided through OFM&K's training portal. As the training provider of choice for ARSA and a trusted resource for the aviation community, the firm's training materials represent a vital tool for entities pursuing regulatory compliance and business success. All of the courses are administered via PotomacLaw.InreachCE.com, which is not part of ARSA's website.
Complying with Part 145 – “Soup to Nuts” (Four Hours) Instructor: Sarah MacLeod Description: Specially recorded with a hand-picked audience for interactive discussion, this session thoroughly reviews 14 CFR part 145, discusses the application of the rule and overviews some practical implications of obtaining and maintaining a repair station certificate. Pricing Note: This is a four-hour session and is $300 for members and $600 for non-members. Click here to register and get access for 90 days.
Sessions Accepted for IA Renewal Credit Eight of ARSA's on-demand training sessions have been accepted by the FAA for Inspection Authorization renewal credit under 14 CFR § 65.93. Each session is currently available for registration and immediate access:Click here to purchase all eight sessions (plus one required prerequisite) at a “bundled” discount – let ARSA take care of your IA renewal requirements this year. Click here to purchase all eight sessions (plus one required prerequisite) at a “bundled” discount.
Aircraft Parts
Audit Activism & Prophylactic Lawyering
Drug & Alcohol Testing
Human Factors
Instructions for Continued Airworthiness
Parts 21, 43, 65, 145 (and others)
Public Aircraft"Going Global" - International Regulatory Law
Grassroots Advocacy
Recordkeeping – "Finishing the Job with Proper Paperwork"
The Fourth Branch of Government (Administrative Agencies and Procedures)
Self Disclosure Programs and Practices
(1) Subscription. Make up-front, bulk purchases of training hours. The details of each subscription can be customized, including focus on specific subject areas (e.g., human factors) or options for specially-priced session access after the initial hours have been used.
(2) “Championing” a session. Guarantee a certain number of attendees for training in a particular topic that will also be made available for general registration. Variations include open registration for a live session (i.e., company personnel participate at the same time as general registrants) or a company-specific live event for which a recorded version (not including any company-specific information) is made available for on-demand registration.
(3) Tailored training. Contract ARSA's management firm Obadal, Filler, MacLeod & Klein, P.L.C. to produce or modify training specific to your organization. The team can then re-record it (or offer it as a separate live session) for ARSA’s training program. Tailored programs are priced differently from ARSA’s hourly rate and are administered by OFM&K, which allows for a client engagement and related attorney-client privilege for all discussion.
For more information about ARSA's training program, review the menus below. If you have questions or would like to learn more about ways to integrate ARSA training into your own program, contact Vice President of Operations Brett Levanto (brett.levanto@arsa.org).The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.
What training do you need? Contact ARSA to let the association know and help get it developed.
From the Ground Up
Bob Ryan of Ryan Strategies International contacted the association after learning of its introduction of aerospace opportunities to Northern Virginia elementary school students.
Sharing his experience with students, teachers, and parents in the Pacific Northwest, Ryan embarks on a series of articles for the association to share strategies and tools for engaging young learners “from the ground up” – starting in pre-school or kindergarten, targeting experiences for every age group through those eligible for FAA certification.
To kick off the series, watch an interview between Ryan and Vice President of Operations Brett Levanto:
The interview provides the background to Mr. Ryan’s interest in and influence on the ability to reach any and all groups by triggering curiosity about all things aerospace.
Opportunities abound to touch local preschools, middle and high schools, libraries, after-school groups, and societies. Providing blankets with airplanes or the universe, books on aerospace to libraries, or toolkits to schools or community centers with company logos would be a simple place to start.
Want to engage ARSA’s efforts to build aerospace careers, contact the association.
Regulatory Compliance Training
Test your knowledge of 14 CFR § 21.31, type design.
Click here to download the training sheet.
Membership
More than Titles
ARSA’s management firm (Obadal, Filler, MacLeod, & Klein, P.L.C.) has contracted with two professionals to support membership and administrative management. From behind standardized email accounts, each will prove to be more than just a title – their service will be invaluable to the association’s team and members.
Meet Nancy and Lora, whose family connections to aviation brought them onto ARSA’s team. Each answered get-to-know-you questions for the hotline and members.
Nancy Builes
The superhero Builes family, including Nancy, ARSA-member husband Will, and newborn son Will.
Executive Manager (aka, “squirrel herder”)
(1) Coming to ARSA’s management firm was a “family affair,” tell us about what brought you to supporting the association?
My journey was completely unexpected. It all started with a digital photo frame I gifted my husband (a repair station manager for a member company) for his new office. During an “Ask ARSA First” online meeting, the photo of our smiling baby in the frame caught Sarah’s eye. My husband shared that we were new parents, and that my goal was to stay home, be the little one’s primary educator, which required me to work remotely. Since the law firm looking for part-time help, what began as a casual conversation became the start of an incredibly fulfilling opportunity. The chance to balance caring for my family while contributing meaningfully to a field I can share with my husband is pretty special. I am grateful for the chance to grow professionally, the patience I’ve been shown, and the kindness extended to me as I stepped into this new chapter.
(2) What were you doing before? How will that experience help you support ARSA’s team?
Prior to becoming Executive Manager, I was a Special Education Teacher. I worked with students with multiple disabilities. My special education knowledge will guide workplace development for the ARSA team and the members. Modifying training materials, creating flexible task assignments, and integrating assistive technology will help promote ARSA’s message and help solve the aviation workforce shortage through inclusive talent strategies. Together we will enable more people are ensuring safety and quality aren’t compromised in the aviation industry.
(3) What does success look like to you?
Success is doing work that matters while staying present for the people that matter most. It’s raising a kind, curious, and confident child. It means making a meaningful impact, constantly growing, and having the freedom to show up for my family.
(4) If you had to give a TED Talk on something without prep, what would it be?
My TED Talk would be about mental health and the gut-brain connection. The gut isn’t just digestion, it’s communication, intuition, and emotion. When your body is out of balance due to diet, stress, or illness, the messages it sends can trigger anxiety, brain fog, and even depression. By exploring the gut-brain connection, we can see how what we eat, how we sleep, and how we manage stress can directly affect our mood, anxiety, and emotional well-being.
(5) What does your ideal workday look like?
My ideal workday starts with baby and self-care. When the baby takes a nap, use that quiet time for focused work; batching similar tasks to reduce mental fatigue is critical. During work hours, I create microbreaks to recharge and refuel. Accepting imperfection is key because the goal is a rhythm that honors both my role as a parent and my part-time work.
Lora Baltes
Administrative Services (aka “member data master”)
(1) Your coming to ARSA’s management firm was a “family affair,” tell us about what brought you to supporting the association?
My partner is a member of the ARSA board and learned there was a need for help. I had already planned to leave my current employment but wasn’t ready to stop working completely. My planned (semi) retirement timed well with the opportunity to help the team.
I have experience in aviation and it is a very interesting industry. I like being involved with it again.
(2) What were you doing before? How will that experience help you support ARSA’s team?
My most recent role was as Director of Financial Operations for a growing company that provides financial, accounting, investor relations, and asset management services to small and family-owned businesses. My role touched on all the services we provided to clients.
My previous experience included 25 years with Honeywell (Grimes Lighting, Urbana, OH) working in the IT and Marketing departments. I interfaced with team members across all departments, seeing the aviation industry from all sides. My experience provides me with the ability to understand the issues facing the industry.
(3) What does success look like to you?
Contributing to the work processes and data organization and standardization that helps ARSA remain a stable, competent association that members can depend on and that other trade groups can use to make the aircraft industry safer and better.
(4) If you had to give a TED Talk on something without prep, what would it be?
How to renovate your house without using professionals and without killing yourself.
(5) What’s one thing that motivates you at work? Or What does your ideal workday look like?
One of my hobbies is doing puzzles. I approach each assignment as a puzzle – what do I need to do to fit all the pieces together and solve the problem? Bringing order and organization to data, seeing all the pieces of the puzzle fit together and make sense, motivates me.
Welcome & Welcome Back – New & Renewing Members
ARSA’s members give the association life – its work on behalf of the maintenance community depends on the commitment of these organizations. Here’s to the companies that joined or renewed in June:
New Members
Airgroup Dynamics, Inc., R03
TAI Acquisition Corporation dba Trimec Aviation Inc, R02
Renewing Members
Able Aerospace Services, Inc., R05, 2024
AeroKool Aviation Corporation, R03, 2017
Aerospace Engineering Group, S.L.-, R03,
Aircraft Tooling, Inc., R01, 2024
Aviation Communication & Surveillance Systems, LLC, R02, 2002
Aviation Repair Resources, Inc., R02, 2009
Component Repair Technologies, Inc., R05, 1995
EXTEX Engineered Products, Inc., Assoc, 2002
Florida Jet Center, Inc., R02, 2013
Little Wolf Consulting, LLC, Affil, 2023
Lynden Air Cargo, LLC, Assoc, 2000
Marana Aerospace Solutions, Inc. dba Ascent Aviation Services, R06, 2023
Marvel-Schebler Aircraft Carburetors, LLC, R02, 2011
MTU Maintenance Hannover GmbH, R06, 2007
NFF Avionics Services, Inc. dba NFF Aviation Services, R02, 2010
REB Technologies Inc., dba REBTECH, R02, 2003
S & T Aircraft Accessories, Inc., R02, 2003
STS Aviation Group, Corp, 2020
Sunvair, Inc, R04, 2024
Texas Air Services, Inc, R02, 2003
Vibrant Corporation, R02, 2021
Warner Propeller and Governor Co., LLC, R02, 2010
A Member Asked…Current data for a less-than-current design?
Q: First and foremost, I want to express my gratitude for your efforts in interpreting FAA regulations. Throughout my career, I’ve encountered numerous situations where it is impossible to obtain clarification from the local FSDO.
I’m writing to address §145.109(d) and the requirement that “documents and data must be current and accessible.”
We operate and maintain a legacy helicopter for which the manufacturer maintained a strict policy on component overhauls, only making the data accessible to service centers. When the TC holder decided to discontinue all support activities, all service centers ceased performing work. Our repair station obtained access to the last revision of all component overhaul manuals, but the TC holder refuses to provide the latest revision or any technical manuals or data. I’ve been trying for years.
How can I establish repair station capability without manufacturer cooperation?
A: Not only did ARSA propose to change § 145.109, but the agency did also in its “MOSAIC” rulemaking (see related updates at arsa.org/current-data). Change is coming…but on government time.
In the meantime, let’s have a discussion of your concerns. If the DAH has stopped supporting the aircraft, and you have the latest version, or even if you did not, the agency would have to prove you didn’t to sustain a violation of § 145.109. There is also the fact that the section’s paragraph (d)(7) allows “other applicable data acceptable to or approved by the FAA.” The FAA’s Chief Counsel’s office has said time and again that any information from the manufacturer unless an AD prohibits the maintenance described is “acceptable to” the agency.
If you are familiar with the Dynamic Regulatory System (DRS), on the left under “Regulation Related Documents and Reports” you will find “Legal Interpretations”, a search on part 43 will bring up the legal interpretations, such as Cash. (Unfortunately, it will also bring up a bunch of part 43 interpretations that don’t apply to § 43.13, so look for that cite in the CFR Section Reference for each option that comes up.)
Have questions about aviation regulatory compliance, legislative policy, or ARSA resources? Ask ARSA first!
Resources
ARSA strives to provide resources to educate the general public about the work of the association’s member organizations; should you need to provide a quick reference or introductory overview to the global MRO industry, please utilize AVMRO.ARSA.org.
Careers in Aviation Maintenance
How do you share the industry’s story with the people who could be its future? Teach them about the great work done every day to keep the world in flight. (Even if we can’t recruit somebody, we sure can make them thankful for our work.)
ARSA Member Benefits
From access to industry expertise to growing your own through education and training, ensure your company gets the most out of its investment in ARSA.
U.S. Legislative Action Center
ARSA requests its members’ assistance to keep FAA reauthorization front and center on the congressional agenda and ensure our workforce priorities are included. Please use ARSA’s grassroots action center (sponsored by Aircraft Electric Motors) to send a quick note to your elected representatives in support of our efforts.
Industry Meetings & Events
| International Conference on Sustainable Aviation | 7/29-30/2025 | Zurich, Switzerland |
| EAA Airventure | 7/21-27/2025 | Oshkosh, Wisconsin |
| LABACE | 8/5-7/2025 | Sao Paulo, Brazil |
| ATEC Fly In | 9/16-19/2025 | Washington, DC |
| MRO Europe | 10/14-16/2025 | London |
| NBAA BACE | 10/14-16/2025 | Las Vegas, Nevada |
| UAFA Annual Conference | 11/19-20/2025 | Boise, Idaho |
| Aerial Works Safety Conference | 12/7-9/2025 | Boise, Idaho |
| ARSA Annual Conference | 3/17-20/2026 | Arlington, Virginia |
the hotline is the monthly publication of the Aeronautical Repair Station Association (ARSA), the not-for-profit international trade association for certificated repair stations. It is for the exclusive use of ARSA members and federal employees on the ARSA mailing list. For a membership application, please call 703.739.9543 or visit arsa.org/membership/join. For information about previous editions, submit a request through arsa.org/contact. This material is provided for educational and informational purposes only. It does not constitute legal, consulting, tax or any other type of professional advice. Law, regulations, guidance and government policies change frequently. While ARSA updates this material, we do not guarantee its accuracy. In addition, the application of this material to a particular situation is always dependent on the facts and circumstances involved. The use of this material is therefore at your own risk. All content in the hotline, except where indicated otherwise, is the property of ARSA. This content may not be reproduced, distributed or displayed, nor may derivatives or presentations be created from it in whole or in part, in any manner without the prior written consent of ARSA. ARSA grants its members a non-exclusive license to reproduce the content of the hotline. Employees of member organizations are the only parties authorized to receive a duplicate of the hotline. ARSA reserves all remaining rights and will use any means necessary to protect its intellectual property.
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